WISH Waste Industry Safety and Health Forum

INFORMATION DOCUMENT

WISH INFO 13 COVID-19 and waste management activities issue 4 6 May 2020 1 of 27

COVID-19 AND WASTE MANAGEMENT

ACTIVITIES

This is version 4 of WISH’s COVID-19 and waste management activities information

document released on 6 May 2020, the original having been released on 2 April,

version 2 on 15 April and 3 on 23 April. It is based on HM Government advice, industry

experience and current knowledge, all of which may change. You should first always

follow the latest HM Government advice (https://www.gov.uk/coronavirus). HM

Government activity on COVID-19 is being led by the Department of Health and Social

Care and PHE (Public Health England) in conjunction with the devolved

administrations. Throughout this document PHE links are provided. Further

information is also available from the devolved administrations via Health Protection

Scotland and Public Health Wales web sites. Links to these sites are provided in

section 6 of this document. Please note this is a fast-moving situation and links may

be superseded between revisions – check that information is the most recent.

Please note that it is NOT the intent of this information sheet to provide a general and

comprehensive ‘one-stop-shop’ for advice on COVID-19. The emphasis here is on

waste management specific issues. You should also read and understand the freely

available HM Government and other advice (such as at the above web address, and the

links given in section 6 and throughout this document) and use these in conjunction

with this document.

This is a ‘live’ document and may be further updated and. If you have a comment on

this document please send it to info@wishforum.org.uk.

Tip – advice, guidance and resources on COVID-19 are available from various sources,

including graphics on how to wash your hands, symptoms and similar. These are generally

free to download and use. Use this type of resource as posters, hand-outs for employees and

similar to reinforce issues such as good hygiene.

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CONTENTS

1. COVID-19, why it may be a problem for waste management and RIDDOR

2. Symptoms and what to do if an employee shows the symptoms

3. Controlling the spread of COVID-19 – general precautions

▪ Good hygiene

▪ Social Distancing

▪ Cleaning procedures

▪ Handling wastes – can I catch it this way?

▪ PPE (personal protective equipment)

▪ Vulnerable persons

▪ Testing for essential workers

▪ First aid provision

4. Changes made in response to COVID-19

▪ Maintaining critical competencies and standards

▪ Change management

▪ Inspections, testing, maintenance and repair

▪ Returning to ‘business as usual’

5. Specific advice

▪ Routine inspections and monitoring

▪ Street cleansing, public waste bins and fly tipped wastes

▪ Vehicles and collections operations

▪ Bulky waste collections

▪ Mobile plant

▪ Landfills, MBT and transfer stations

▪ MRFs and recycling plants

▪ CA/HWRC sites

▪ Welfare facilities

▪ Weighbridges

6. Other information and links

Disclaimer and WISH

For ease of accessing updates a brief summary of significant changes since the last version

of this document is provided in green italic text at the start of each section.

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1. COVID-19 and waste management

Changes from previous version: There are no significant additions/changes to this section.

We have an unprecedented situation which requires information to be provided swiftly. The

below is based on advice and information available at the time of preparation and may be

updated. Please check the issue number and date against the copy held on the WISH

website (https://wishforum.org.uk/) to ensure you have the most up to date version.

What is COVID-19 and why is it a problem?

Coronaviruses are a large family of viruses that can cause illness such as respiratory tract

infections. This novel coronavirus, known as SARS-CoV-2, is a new strain that has not been

previously identified in humans. The virus is a problematic pathogen due to how easily it is

apparently spread from human to human. Currently it is thought when uncontained one

person may infect up to three others, even when asymptomatic (not showing any symptoms).

Why COVID-19 may be a problem for the waste industry?

To limit the spread of the disease it is important that individuals self-isolate if they, or their

family, have symptoms, or if they are vulnerable. This could result in significant absence from

work. Estimates of the impact vary, but at a low-end 15% of workers may be absent, and at a

high-end some estimates range to in excess of 50%. Such levels of absence would very likely

have a significant effect on the delivery of essential waste management activities.

COVID-19 and RIDDOR reporting

The HSE (Health and Safety Executive) has released guidance on reporting of COVID-19

cases under RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences

Regulations). See: https://www.hse.gov.uk/news/riddor-reporting-coronavirus.htm. However,

just because a waste operative may potentially have contracted COVID-19 from a workmate,

such as if they shared a vehicle cab during their work, this would not on its own make this

reportable as an exposure to a biological agent at work without further evidence of direct

causation. Reporting would likely only be applicable if a worker is knowingly dealing with

those with COVID-19 or symptomatic persons as part of their job, such as those working in

the healthcare sector. Further information is available at the link above and in section 6 of this

document. If in doubt, contact the HSE for advice.

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2. Symptoms and what to do if an employee shows or reports the symptoms

Changes from previous version: The only significant addition/change to this section is on

adverse reaction towards and training for returning employees.

What are the symptoms?

The primary symptoms are reported as being fever and dry cough. For more detail see

https://www.nhs.uk/conditions/coronavirus-covid-19/symptoms-and-what-to-do/.

What to do if an employee shows the symptoms of COVID-19

Please also first see https://www.gov.uk/government/publications/guidance-to-employers-

and-businesses-about-covid-19/guidance-for-employers-and-businesses-on-coronavirus-

covid-19#what-to-do-if-someone-develops-symptoms-of-coronavirus-covid-19-on-site and at

https://www.nhs.uk/conditions/coronavirus-covid-19/symptoms-and-what-to-do/.

Current Public Health England (PHE) advice is that: “If anyone becomes unwell with a new,

continuous cough or a high temperature in the business or workplace they should be sent

home and advised to follow the stay at home guidance

(https://www.gov.uk/government/publications/covid-19-stay-at-home-guidance).

“If a member of staff has helped someone who was taken unwell with a new, continuous

cough or a high temperature, they do not need to go home unless they develop symptoms

themselves. They should wash their hands thoroughly for 20 seconds after any contact with

someone who is unwell with symptoms consistent with coronavirus infection.”

From the above, if a person with no symptoms themselves has only been in indirect or

potential contact with someone who has or is suspected of having COVID-19, there is no

reason for them to stop work and go home. Likewise, if one employee has been confirmed or

is suspected of having COVID-19 there is no need to send the whole of the rest of the

workforce home, although thorough cleaning of the area they work in (office/cab/rest room

etc) is recommended (see links below under cleaning procedures for advice).

Should an employee show the symptoms of COVID-19 while at work:

▪ Instruct them to leave work immediately and follow HM Government advice, even if

they state they feel well enough to continue to work

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▪ Instruct them to stay at home to recover and follow HM Government advice, which is

currently to self-isolate unless symptoms become worse, in which case they should

follow NHS advice via https://111.nhs.uk/covid-19 (or at

https://www.nhsinform.scot/self-help-guides/self-help-guide-coronavirus-covid-19, or

at https://www.nhsdirect.wales.nhs.uk/contactus/ as appropriate)

▪ Instruct them not to return to work until free of fever, feeling well enough AND a

minimum of 7 days have elapsed since the first onset of symptoms (see also HM

Government advice on this – as isolation may need to be longer. See:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachm

ent_data/file/877678/coronavirus-leaflet.pdf

▪ Instruct them to contact their workplace should they subsequently be confirmed as

having COVID-19 (provided they are well enough to make such contact)

▪ Instruct them to contact their workplace after the 7 days (as above) have elapsed and

if they are well enough to return to the workplace

▪ Clean their work area (office, vehicle cab and similar) thoroughly before allowing other

persons to access them (see links below under cleaning procedures for advice)

Should an employee develop symptoms while not at work, they should be instructed to notify

you via telephone, e-mail, text or similar that they believe they have the symptoms. They

should be instructed NOT to come into work to inform you. The same basic process as above

should then be followed.

Employees returning to work after a period of self-isolation, or having recovered from COVID-

19, may face adverse reaction from their workmates for reasons of a perceived continuing

risk of infection. Whatever the validity or otherwise of such reactions, employers should be

aware of this risk and manage returns to work to avoid potential discrimination. For example,

the reinforcement of anti-bullying policies and similar.

Employers should also consider, dependent on the length of absence, whether returning

workers require reinforcement or repeat training and/or updating on any changes in work

methods, processes and controls which may have been made during their absence.

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3. Controlling the spread of COVID-19 – general precautions

Changes from previous version: Significant additions/changes to this section include

home-laundering of workwear, masks/face-coverings used for reassurance rather than

protective reasons, testing for essential workers and first aid provision.

Controlling the spread of COVID-19 Full details of how COVID-19 is transmitted are still unknown (see:

https://www.nhs.uk/conditions/coronavirus-covid-19/symptoms-and-what-to-do/ for more

details). The two main methods being used to reduce transmission are good hygiene and

‘Social Distancing’. Please also see Defra advice specific to the waste management industry

at https://www.gov.uk/guidance/social-distancing-in-the-workplace-during-coronavirus-covid-

19-sector-guidance#waste-management-businesses.

Good hygiene

The MOST important control for preventing the spread of any infection is good hygiene. This

cannot be over-emphasised. Good hygiene practices should already be in place in waste

management operations – these MUST be maintained. Employees should be instructed to:

▪ Use tissues to cover their mouth and nose when they cough or sneeze (CATCH IT)

▪ Place used tissues in a bin (or bag) as soon as possible (BIN IT)

▪ Wash their hands regularly with soap and water (KILL IT)

▪ Clean surfaces and contact points regularly to get rid of germs (KILL IT)

For the above to be effective, employees need to have tissues available and, if they are not

site based, bags available to dispose of used tissues. Employers should provide these.

‘Social Distancing’ In addition to good hygiene, the use of ‘Social Distancing’ is also included in HM Government

advice (see https://www.gov.uk/government/publications/covid-19-guidance-on-social-

distancing-and-for-vulnerable-people/guidance-on-social-distancing-for-everyone-in-the-uk-

and-protecting-older-people-and-vulnerable-adults). This means keeping at least 2 metres

(>6 feet) away from other people.

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Social Distancing may pose issues for some waste management activities – see specific

advice section below. In general, you should consider precautions such as staggering shift

changeovers, not requiring drivers to collect lorry keys in person, staggering use of welfare

facilities, limiting the number of people allowed at any one time in offices, welfare facilities

and other areas and similar.

Note – searches on the internet and similar may reveal older and superseded advice on

Social Distancing. Such searches may also reveal definitions from other countries and/or

guidance aimed at industries and sectors other than waste management. Current HMG and

waste management industry applicable definitions and advice should be used.

Cleaning procedures etc

Cleaning procedures should already be of a high order in any waste activity for basic hygiene

reasons. HM Government advice specifically in relation to COVID-19 is available at

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_dat

a/file/876221/COVID19_Guidance_Cleaning.pdf and at

https://www.gov.uk/government/publications/covid-19-decontamination-in-non-healthcare-

settings. You should reinforce cleaning arrangements and consider the below:

▪ Ordinary cleaning, such as with soap and water, alcohol sprays, normal cleaning

agents or disinfectant, will kill virtually all virus

▪ Damp dusting should replace any dry dusting

▪ Telephones and computer equipment should also be cleaned with wipes or by other

means by following HM Government guidance

▪ If an employee has gone off sick with COVID-19, their workstation, including

telephone and keyboard, vehicle cab etc should be cleaned using normal cleaning

materials and methods

▪ Cleaning of crockery and utensils can be conducted using hot water and detergents

▪ Shared facilities, such as toilets and showers, should be cleaned frequently, including

door handles, toilet flush handles/buttons and similar ‘touch surfaces’

▪ Good hygiene should be maintained regards workwear and laundry services. Used

workwear should be placed in bags for laundry and not left in a ‘pile’. Laundry bags

should themselves be laundered (to prevent secondary contamination) or disposable

bags used and suitably disposed of when the workwear is laundered. See also

guidance at https://www.gov.uk/government/publications/covid-19-decontamination-in-

non-healthcare-settings/covid-19-decontamination-in-non-healthcare-settings\

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▪ In some cases, employees take their workwear home to launder. In these situations,

employees should change out of their workwear before going home. Workwear should

be bagged, such as in a ‘bin-bag’, and the same precautions as in the link above

taken, such as using a ‘hot’ wash-cycle

Handling wastes – can I catch it this way?

Latest research indicates the virus could survive on cardboard for 24 hours, and

metal/plastics for up to 72 hours. It is important to note this work exposed these surfaces to

high concentrations in a laboratory environment and is likely to be the ‘worst case’ scenario. It

is good practice to ensure a high standard of hygiene when handling waste materials, as

should always be the case in all waste management activities. The virus survives on the skin

for more than enough time to allow hand to mouth/nose/eyes transmission.

There may be discarded materials from individuals who are themselves infected with COVID-

19. The public are being educated to double bag any discarded tissues and leave for 72

hours before placing them in their main residual waste bin/bag (see:

https://www.gov.uk/government/publications/covid-19-stay-at-home-guidance/stay-at-home-

guidance-for-households-with-possible-coronavirus-covid-19-infection.

Waste management employees undertaking tasks, which may bring them into contact with

wastes, should already be working under appropriate precautions, such as good glove use.

These precautions should continue.

Where waste has already been designated as ‘clinical waste’, clinical waste procedures

should already be in place. Those procedures can be followed as normal.

PPE (personal protective equipment)

Two types of PPE are often quoted in relation to COVID-19: gloves and masks.

Gloves. To be effective glove use needs to be in conjunction with good hygiene measures,

and good ‘glove discipline’. For example, if an employee stops work to eat/drink/smoke the

basic process is gloves off, wash hands thoroughly, eat/drink/smoke, wash hands again, put

gloves back on. For more information see https://www.hse.gov.uk/skin/employ/gloves.htm.

Employees should be made aware of the limitations of glove use, such as touching their

faces while wearing gloves which may be contaminated, and that gloves are no substitute for

good hygiene and hand washing.

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Gloves should already be in use for many waste management activities, and this should

continue. In the case of reducing the risk of transmission, gloves should:

▪ Be impermeable/waterproof

▪ Or, supported by use of impermeable gloves used underneath standard gloves

Employees must be provided with an adequate supply of gloves and instructed to change

gloves at a frequency appropriate to the type of glove and its use, and that glove use does

not mean that good hygiene and hand washing are not required. For further details on glove

selection and use see https://www.hse.gov.uk/skin/employ/latex-gloves.htm.

Masks. One item of PPE which has been the subject of publicity is the use of face masks.

The need for RPE (respiratory protection equipment) to protect from coronavirus must be

based on risk assessment. For example, current guidance states that healthcare workers

undertaking high risk aerosol generating procedures on COVID-19 patients are required to

wear FFP3 respirators, whereas those looking after patients with COVID-19 wear fluid

repellent surgical masks. Waste industry workers are unlikely to encounter the same level of

risk as either of these examples. However, where a risk assessment has previously indicated

that an employee would be expected to wear respiratory protection as part of their normal job

then they should continue to do so.

On face masks, Public Health England (PHE) currently states: “We do not recommend the

use of facemasks as an effective means of preventing the spread of infection. Face masks

play an important role in clinical settings, such as hospitals, but there’s very little evidence of

benefit from their use outside of these settings”. Prolonged use of masks may also have

problems. For example, wearers may be tempted to adjust the fit frequently risking hand to

face contact, masks may become moist so trapping contaminants, germs and similar.

Experience is that the prolonged use of RPE is unlikely to be effective. Further advice is

available at https://www.gov.uk/government/publications/guidance-to-employers-and-

businesses-about-covid-19/guidance-for-employers-and-businesses-on-coronavirus-covid-19.

Notwithstanding the above where an organisation does decide to use RPE:

▪ Their risk assessment must include the risk of employees placing overreliance on

RPE to the detriment of other more effective controls such as good hygiene and

Social Distancing, resulting in a higher not lower risk of transmission, AND what will

be done to reduce this risk

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▪ Their risk assessment should also include a clear description of the reasons why RPE

is to be used AND the limits and specific situations for use

▪ Limit use of RPE to short periods and only in specific situations were adequate Social

Distancing may not be reasonably practicable – multiple research indicates that the

prolonged use of RPE is unlikely to be effective

▪ Instruction of employees in the use, storage, replacement, and disposal of RPE, AND

the limitations of RPE as a precaution AND the risks associated with overreliance on

RPE to the detriment of other more effective precautions

In addition to the above, where an employer decides to provide basic masks/face-coverings

for reasons of reassurance, rather than for personal protective reasons, employers may want

to make this clear – that the mask or other face-covering is being provided for reassurance

and should not be relied on as protection. In a similar manner, where an employee decides

for their personal reasons of reassurance to use their own basic mask or face-covering while

at work, employers may wish to communicate that such basic masks/face-coverings should

not be relied on as protection. Consideration may also need to be given to interface issues,

such as mask/face covering use impairing vision for drivers if worn too high or with glasses.

For more information see https://www.hse.gov.uk/respiratory-protective-equipment/types-

rpe.htm and https://www.hse.gov.uk/news/face-mask-ppe-rpe-coronavirus.htm.

Note – some organisations are reporting shortages of specific types and standards of PPE,

such as some types/standards of gloves and masks. Where alternative types and standards

of PPE are being considered to address any such shortages employers should ensure that

the level of protection remains adequate. Employers should also be wary if offered alternative

types/standards of PPE that they are unfamiliar with as a replacement. If in doubt competent

advice should be sought and, as applicable, risk assessments reviewed.

Comment – some readers of this document have raised the question of the disposal of used

PPE. For used PPE generated from the healthcare and similar sectors guidance is already in

place. For used PPE from other sectors, including waste management, and from the public,

whose use of PPE such as masks and gloves seems likely to increase, PPE should be

disposed of into residual waste streams. Most PPE is not recyclable and can reduce the

quality of recycling waste streams.

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Vulnerable and extremely vulnerable persons

Persons with pre-existing conditions, or other individual factors, may be more prone to

suffering more serious effects from COVID-19. See link below for what may make someone a

vulnerable or extremely vulnerable person and advice:

https://www.gov.uk/government/publications/covid-19-guidance-on-social-distancing-and-for-

vulnerable-people/guidance-on-social-distancing-for-everyone-in-the-uk-and-protecting-older-

people-and-vulnerable-adults and at https://www.gov.uk/government/publications/guidance-

on-shielding-and-protecting-extremely-vulnerable-persons-from-covid-19/guidance-on-

shielding-and-protecting-extremely-vulnerable-persons-from-covid-19.

Current HM Government advice is that vulnerable persons should practice stringent Social

Distancing and that extremely vulnerable persons should self-isolate (stay at home). Should

an employee be suspected of or confirmed with COVID-19 you should assess whether you

employ any vulnerable or extremely vulnerable persons.

Testing for essential workers

Waste management workers perform an essential service. Essential workers can now

request testing for COVID-19 if they believe they are showing the symptoms of COVID-19, or

another member of their household is showing symptoms. Testing can be either via a

regional drive-through test site or by home-test kit. See

https://www.gov.uk/guidance/coronavirus-covid-19-getting-tested for details.

There are some detail differences regards testing schemes and the definition of essential

workers in the devolved administrations. See https://gov.wales/coronavirus-covid-19-testing-

process and https://www.gov.scot/publications/coronavirus-covid-19-getting-tested/ for

information.

First aid provision

First aiders may, by the nature of what they do, come into close contact with persons they are

treating. Specific information is available at:

https://www.gov.uk/government/publications/novel-coronavirus-2019-ncov-interim-guidance-

for-first-responders/interim-guidance-for-first-responders-and-others-in-close-contact-with-

symptomatic-people-with-potential-2019-ncov, and from the St John’s Ambulance web site at:

https://www.sja.org.uk/get-advice/first-aid-advice/covid-19-advice-for-first-aiders/.

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4. Changes in response to COVID-19

Changes from previous version: The only significant change/addition to this section is on

recommencement of services involving going onto third party sites, such as commercial

waste collections at customer sites, and further guidance on reopening HWRC/CA sites.

Maintaining critical competencies and standards

Waste operations require minimum standards of safety and competency. Any contingency

and similar measures taken in regard to COVID-19 must not compromise these.

Health and safety requirements, such as plant operator licences, permits to work, machinery

lock off and isolation etc. MUST NOT be compromised: COVID-19 is not an excuse to reduce

safety or training requirements. For example, reducing crew size in household collections to

the point that safe reversing procedures cannot be followed.

Environmental permit/licence and other legal requirements must be maintained even during

any widespread COVID-19 outbreak. If you plan to take any contingency or similar action,

which may affect your permit/licence or have an environmental impact, you should contact

your environmental regulator first, and you would be advised to keep up-to-date on any

announcements, temporary regulatory position statements and similar from your regulator

relating to COVID-19.

Change management

In response to the COVID-19 pandemic many organisations are making temporary changes

to the way they operate. Health and safety should be a core consideration when considering

such changes to avoid unintended consequences. For example, closing CA/HWRC sites may

remove the risk of transmission at such sites, but may also result in an increased demand for

bulky waste collections, which may be simply moving a problem from one place to another.

Any modification to work equipment, including vehicles and machinery, in response to

COVID-19 must be considered very carefully to avoid compromising other safety features,

emergency escape and similar. Good change management is critical with any modification of

work equipment.

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Some employers have installed, or are considering installing, Perspex or similar ‘screens’ in

their workplaces and/or vehicle cabs, similar to those which have been installed in some

supermarkets at check-outs or those already in place for security reasons in buses or other

public transport vehicles. Dependent on their design and placement, screens may reduce, to

an extent, the risk from projected particles/aerosols, such as produced when someone

coughs, but there is little evidence currently that they are effective in preventing the spread of

viruses. Notwithstanding the above where an organisation does decide to consider screens:

▪ A design change risk assessment should be performed to ensure that safety

arrangements and features, such as emergency escape, machinery safety provisions

and fixed fire systems, are not adversely affected by the installation of screens

▪ The change risk assessment must include the risk of employees placing overreliance

on screens to the detriment of other more effective controls such as good hygiene and

Social Distancing, resulting in a higher not lower risk of transmission, AND what will

be done to reduce this risk

▪ The risk assessment should also include a clear description of the reasons why

screens are to be installed AND their limitations

▪ Instruction should be given to employees on the limitations of screens as a precaution

AND the risks associated with overreliance on screens to the detriment of other more

effective precautions

▪ Screens should be subject to the same cleaning regimes as other equipment

Please also see specific mentions of screens below under the sections on vehicles and

collections operations and MRFs and recycling plants.

Changes to ways of working, procedures, operations, PPE use and similar may need to be

put in place quickly during the pandemic. However, changes still need to be considered

carefully to ensure any health and safety consequences are assessed, including as

appropriate whether they meet the test of being ‘reasonably practicable’ (see

https://www.hse.gov.uk/risk/theory/alarpglance.htm). Likewise, relevant parties should still be

involved when making decisions:

▪ Consult with employees on changes. They may have a different perspective or place a

different level of importance on an aspect of any change. They may also have

knowledge and experience not held by management

▪ If a change involves third parties, such as customers and clients, consult with them

▪ For some changes, the involvement of specialists or external competent persons may

be required or advised

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Tip – decisions and changes made quickly may not be recorded with normal rigour.

Organisations may be wise not to forget this aspect and ensure they record their decision-

making process, risk assessments and similar which led to any change and the detail of the

change, including the involvement of third parties, employee representatives and similar.

Staff shortages and changes to ways of working may result in longer working hours.

Employees may also, understandably, have concerns about their work and COVID-19 risk

(whether these concerns are well founded or not they may be very real to the employee). In

addition, changes to services, such as HWRC/CA site operation and collections, may result in

adverse responses from members of the public and others.

▪ Employers should monitor working hours to ensure that safety standards are not

degraded, and be aware of the risks associated with fatigue (see:

https://www.hse.gov.uk/humanfactors/topics/fatigue.htm and

https://www.hse.gov.uk/humanfactors/topics/specific2.pdf for further advice)

▪ Employers should consider the mental health and wellbeing of their workers during the

current crisis. This may not be directly work related, but employers may want to make

information available such as at: https://www.nhs.uk/oneyou/every-mind-

matters/?WT.tsrc=Search&WT.mc_id=Brand&gclid=EAIaIQobChMI6qHAmoz86AIVh

OF3Ch1ENg7uEAAYASAAEgKNi_D_BwE. Resources are also available at:

https://campaignresources.phe.gov.uk/resources/campaigns/82-every-mind-

matters/resources

▪ Changes to services may result in adverse reaction from the public, including

aggressive and violent behaviour. As relevant, workers should be informed that all

such must be reported and that in serious cases the police should be called. As is the

case for any assault on a worker consideration should be given their mental and

physical wellbeing including referral to counselling or medical services as appropriate

Inspections, testing, maintenance and repairs Concerns relating to the examination of equipment, such as under the Lifting Operations and

Lifting Equipment Regulations (LOLER) have been raised (see:

https://www.hse.gov.uk/news/assets/docs/loler-pssr-during-outbreak.pdf). At the current time,

the HSE (Health and Safety Executive) has not issued any exemptions or relaxation of these

requirements. Inspections of equipment should continue to be done, and can be done safely,

following Public Health England guidance (see:

https://www.gov.uk/government/publications/guidance-to-employers-and-businesses-about-

covid-19/guidance-for-employers-and-businesses-on-coronavirus-covid-19).

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Tests, inspections, daily/weekly and similar checks, critical maintenance and similar must be

maintained, unless legal derogations are put in place dictating otherwise.

Engineers who are working on sites where there are restrictions arising from the risk of

COVID-19 infection should comply with site rules and Public Health England advice regarding

good hygiene practices and separation distances. Consideration needs to be given to

protecting engineers but also, where relevant, any vulnerable persons who may be affected

by their work. Such measures should already be in place at waste management operations

and include for example the cleaning-down of equipment, mobile plant and vehicles before

any maintenance and repair, and the use of appropriate PPE during such activities.

Returning to ‘business as usual’ COVID-19 has resulted in various changes to waste management services, perhaps most

notably and commonly the suspension of green and bulky waste collections and the

temporary closure of HWRC/CA sites. Whatever the changes made, resumption of services

needs careful consideration and planning. Waste management operators, and their clients,

should start to plan in advance now for the resumption of services and returning to ‘business

as usual’, or at least more normal services. How and when services return to normal, or

closer to normal, may in some circumstances depend on national policy. The detail of such

policy may vary between England, Scotland and Wales. Operators should check that they are

following the policy relevant to the location of their operations.

Where waste collection services, such as green and bulky waste collections, have been

suspended, there may be a backlog of waste waiting for resumption of service. Waste

management operators, and as applicable their clients, may want to consider:

▪ Phased resumption, such as not resuming all services at the same time

▪ Any additional resources required to tackle any backlog

▪ Communication with the public regarding the resumption of services, how this will be

handled and any restrictions which will be in place

▪ For commercial waste collections, close communication with customers and clients to

ensure that as they reopen services can be resumed in an orderly and safe manner

Where HWRC/CA sites have been temporarily closed their reopening needs to be planned

carefully. Waste management operators, and their clients, may want to consider:

▪ Phased opening of HWRC/CA sites rather than opening all sites at once

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▪ Partial opening, such as only accepting specific types of waste in the short-term. For

example, only accepting green and bulky wastes for the first few weeks

▪ Use of pre-booked time slots for members of the public rather than allowing everyone

to simply turn-up at the HWRC/CA site

▪ Restricting access, such as by post code or ‘odd/even’ car registrations on different

days to allow phasing of initial demand

▪ Restrictions on the number of cars allowed into a site at the same time, and using a

‘one-in-one-out’ approach when safe capacity is reached

▪ Queuing capacity, both on and off site, and how this will be managed. And, for off-site

queuing advance communication and discussion with the local police force, and

consideration of any police resource requirements

▪ Closing-off alternate car parking spaces to aid Social Distancing

▪ Reduced or extended hours of opening dependent on specific situations

▪ Use of floor markings (tape or paint) to reinforce Social Distancing

▪ Additional resources which may be required to manage any backlog

▪ Communication with the public regarding the resumption of services, how this will be

handled, any restrictions on services which will be in place and similar

▪ External support which may be required, such as from the police, to manage the safe

and orderly reopening of HWRC/CA sites, and communication and planning with such

external resources before sites are reopened

See also section 5 on HWRC/CA site operation. Further guidance is also available at:

https://www.gov.uk/government/publications/coronavirus-covid-19-advice-to-local-authorities-

on-prioritising-waste-collections/managing-household-waste-and-recycling-centres-hwrcs-in-

england-during-the-coronavirus-covid-19-pandemic and at https://1ur6751k3lsj3droh41tcsra-

wpengine.netdna-ssl.com/wp-content/uploads/2020/05/4-April-2020-NAWDO-HWRC-

reopening-guidance-FINAL.pdf.

Some waste management operations, such as commercial waste collections, involve

employees going onto third party company sites, such as customer sites. These third parties

may have introduced additional controls or made changes to their ways of working in

response to COVID-19. Operators should check before recommencing service. As has

always been the case there is a duty on employers to communicate and co-operate on health

and safety matters, and this would include on changes made in response to COVID-19.

The suspension of various waste management services was achieved quickly in response to

the COVID-19 crisis. The safe resumption of services is likely to be more complicated and

time consuming and requires careful thought and planning in advance.

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5. Specific advice

Changes from previous version: Significant additions/changes to this section include

addition of COVID-19 issues to routine inspections and monitoring, fly-tipped wastes, use of

precautions for cabs and crew and used PPE from the public being disposed of into recycling

waste streams rather than residual streams.

The sections below contain advice, such as for specific waste management operational types

and functions. These operational types are varied, and you should assess your own specific

operations, using the below, and reasonable practicability as appropriate, as a starting point.

Please also see the advice given at: https://www.gov.uk/guidance/social-distancing-in-the-

workplace-during-coronavirus-covid-19-sector-guidance?utm_source=075ed450-af83-4469-

8137-749615f595ea&utm_medium=email&utm_campaign=govuk-

notifications&utm_content=daily#waste-management-businesses.

Routine inspections and monitoring

Employers carry-out routine ‘safety inspections’ to check that required standards are being

met. This may be through regular workplace/site ‘safety tours’ or monitoring of standards

during waste collections. Where changes have been made as a result of COVID-19, such as

requiring Social Distancing during work, these should be incorporated into inspection and

monitoring regimes. Putting in place an additional control aimed at COVID-19 is only part of

the equation, checking to ensure controls actually occur is also required.

Street cleansing, public waste bins and fly-tipping Litter and the contents of litter bins can include drug paraphernalia and may have been

frequented by rodents. Clearing fly-tipped wastes may result in potential exposure to a variety

of hazards, dependent on the nature of the wastes fly-tipped. Precautions and procedures

should already be in place to ensure that persons collecting/clearing such materials are

suitably protected from harmful substances, biological agents and similar.

Litter and the contents of litter bins, including gloves and masks discarded by the public while

out exercising, shopping for food and similar, can be collected and bagged using the normal

precautions and procedures. Fly-tipped wastes should be approached as before through

assessment of the nature of the wastes and implementation of controls appropriate to the

hazards posed. In both these cases, if adequate precautions are already being taken,

additional controls should not be required related to COVID-19.

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Vehicles and collections operations Obeying 2-metre Social Distancing may be not be reasonably practicable for personnel who

work together in the cabs of some waste collection vehicles. However, as an essential service

it is important collection operations continue. What is reasonably practicable will depend on

the specific circumstances of each collection methodology and type and each collection area.

When deciding upon the measures to take consideration should be given to the following.

Note – the advice given below applies to both household and commercial/industrial waste

collection operations. In some cases, such as any need for shared lorry cabs, the issues

faced may be more exacerbated for household compared to commercial/industrial waste

collections, but the principles remain the same.

▪ Can the collection be suspended, or reduced? For commercial and industrial waste

collections many customers may be closed for business or running at reduced

capacity – collections from such customers could be suspended, or the frequency of

collection reduced. For household collections it may be worth considering suspending

some types of collection, such as green waste and bulky waste collections (but, see

above on change management to avoid unintended consequences)

▪ If reasonably practicable, use single-person operation. For many commercial and

industrial waste collections this is already the case, and for others it may be practical

to reduce twin-person operation to single-person, provided that safety standards are

not compromised. Other than in limited cases, for household collections single-person

collection operation is very unlikely to be reasonably practicable or safe, in which case

please see below

Having considered the above, the below applies to ALL collection activities, and in addition to

the general precautions given above:

▪ Cabs should have available alcohol- or soap-based cleansing and/or wipes available

for all surfaces which should be cleaned periodically throughout the day and

especially at the end of each shift. Cleaning should pay particular attention to door

handles, hand holds/rails, dashboards, steering wheels, hand-brake levers, gearbox

and other controls and indicator stalks etc. Do not forget external touch-surfaces such

as lifting equipment and compaction control buttons and levers

▪ Where fitted, ‘pop-up’ sinks on waste collection vehicles should be subject to the

same rigorous cleaning regimes as for any other welfare facility. Where pop-up sinks

are fitted, disposable paper towels or similar should be available to dry hands

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▪ Where a vehicle may have been used by someone displaying the symptoms of

COVID-19, or a confirmed case, then the vehicle should either be decontaminated

thoroughly (see advice at https://www.gov.uk/government/publications/covid-19-

decontamination-in-non-healthcare-settings/covid-19-decontamination-in-non-

healthcare-settings) or if this is not reasonably practicable parked up and not used for

a minimum of 72 hours

▪ Collections operations may result in contact with members of the public/customer

employees. Social Distancing should be followed (at least 2 metres/>6 feet away from

other persons). Should this prove impossible, such as a member of the public not

being willing to ‘stand away from their bin’ the waste should not be collected. In

extreme cases members of the public may display aggressive and potentially violent

behaviour. All such cases must be reported, and collections operatives informed to

contact the police immediately if they are threatened. As is the case for any assault on

a worker consideration should be given their mental and physical wellbeing including

referral to counselling or medical services as appropriate

▪ Safety precautions which would normally be taken, such as the use of respiratory

protection during the collection of waste which is particularly dusty or might shed

significant fibres must be maintained

▪ Normal monitoring processes aimed at checking that crews are following good

standards of safety should be continued, and the scope of such monitoring extended

to include maintenance of Social Distancing and enhanced concentration on good

hygiene practices and glove-use

▪ Normal precautions aimed at reducing the risk of ‘sleepers in bins’ and hazardous

items in waste streams, such as gas cylinders, should be maintained

If single-person collection operation has been assessed as not being reasonably practicable,

such as is likely for most household waste/RCV (refuse collection vehicle) activities, or is

likely to be unsafe, then in addition to the above and the general precautions given elsewhere

in this document:

▪ Consideration should be given to reducing the number of persons who share cab

space. In some areas it might be possible for crews to travel independently to an area

or estate and work as a group to fill RCVs that are sent with individual drivers and

which go off to tip sequentially as they are filled and return. It is recognised, however,

that there will be cases where such alternative methodologies cannot reasonably

practicably be used. Where this is the case the primary control method is to maintain

high standards of hygiene

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▪ Having considered the above, where reasonably practicable, time spent in shared

cabs should be minimised, although it is accepted this may not always be achievable

▪ Where alternative methods either of transporting employees to collection points, or

collection, is used organisations MUST take suitable and sufficient measures to

ensure that employees still have access to a sufficient supply of soap and water,

alcohol-based sprays or wipes and other materials for them to be able to maintain a

high standard of hygiene and that collection operatives maintain Social Distancing

during actual collection of wastes

▪ Where minibuses and similar are used to ferry employees to collection areas they

should be subject to the same cleaning processes as given above for lorry cabs

▪ Where practical maintain consistent crew rosters (same crew in each team every day)

and minimise close interactions between crews. It is recognised that absence and

crew competency requirements may limit the extent to which this is possible

▪ If safe to do so, crews may be dropped-off outside waste management sites so that

only the driver proceeds to tipping areas before picking the crew up on the way out

▪ Open cab windows to encourage airflow (see: https://www.gov.uk/guidance/social-

distancing-in-the-workplace-during-coronavirus-covid-19-sector-

guidance?utm_source=075ed450-af83-4469-8137-

749615f595ea&utm_medium=email&utm_campaign=govuk-

notifications&utm_content=daily#waste-management-businesses)

Note – waste collections and locations vary widely. For example, the size of vehicle (and

often therefore cab) used in a medieval town centre will likely be smaller than used in a

suburban area. Likewise, the number of crew need to safely transport the waste to the vehicle

may vary dependent on local circumstances and waste collection methodology. As a result,

no fixed minimum or maximum number for cab occupancy can be given. However, in all

cases the aim should be to reduce the numbers sharing cabs so far as is reasonably

practicable, and once this has been achieved implement other controls to reduce any

remaining risk to as low as is reasonably practicable.

Where multiple-person crews are being used and lorry cabs are being shared, if a member of

a crew develops the symptoms of COVID-19, or they contact their manager/supervisor to

state that they have developed symptoms:

▪ The cab must be decontaminated (see link above) or the vehicle parked-up for at least

72 hours. If a crew member develops symptoms partway through the working day, this

must be done immediately even if it means aborting the collections round

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▪ The crew member showing symptoms must be sent home immediately

▪ All crew members MUST immediately wash their hands thoroughly

▪ If at all reasonably practicable the remaining crew should not be allocated to a

different crew, nor should a crew member from a different crew be allocated to fill the

gap left by the person who has developed symptoms, unless they can travel

separately and maintain Social Distancing when working. The time period for this type

restriction, seven, 14 days or longer, will depend on the situation. The principles at

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachm

ent_data/file/874011/Stay_at_home_guidance_diagram.pdf may assist in informing

employers regards an appropriate time period for restrictions

▪ Reinforcement instruction on precautions such as maintaining good hygiene should

be conducted for all crews

If the above hierarchy of considerations is followed, required measures taken, and good

hygiene practices enforced, the residual risks to employees will be minimised and will be low.

Some organisations have fitted, or are considering fitting, Perspex or similar screens in

vehicle cabs (see section above under change management). Specific to cabs, and in

addition to the general design risk assessment requirements noted in the section above on

change management, the following should also be considered:

▪ The material used should be appropriate to reduce risks such as the screen shattering

in the event of a road traffic collision producing shards which may cause injury

▪ The blocking of or impeded access to safety critical controls

▪ Distortion of driver vision resulting from an installed screen

▪ Screens should be subject to the same cleaning regime as the rest of the cab

▪ Emergency escape from the cab

If the installation of screens is being considered, advice should be sought from the vehicle

manufacturer/supplier or a suitably qualified and experienced vehicle engineer to ensure

critical safety aspects are not compromised.

Note – the above are not ‘either/or’ choices. For example, a household collection service may

normally involve a driver and three crew. It may be decided that reducing to driver only with

crew members being ‘shuttled’ to and from collection areas is not reasonably practicable.

This does not mean automatically that nothing should change – for example, can the number

sharing a cab be reduced to the driver and one, or two, crew members?

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Bulky waste collections Concerns have been raised about the risks associated with the collection of soft furnishings,

mattresses and similar items as part of bulky waste collections.

Such items have the potential to be contaminated with a wide range of insects, parasites, and

potentially harmful organisms many of which survive longer in the environment than

coronaviruses. Existing risk assessments for the collection and handling of such items should

have considered this potential and identified controls. This might include wearing gloves and

other protective equipment. Plus, instructions that where such items are dusty or shedding

large numbers of fibres precautions should be taken which might include the damping of the

waste with water or a disinfectant and/or the wearing of a dust mask.

Mobile plant In addition to the above general measures:

▪ Cabs should have available alcohol- or soap-based cleansing spray and/or wipes

available for all surfaces which should be cleaned periodically throughout the day and

especially at the end of each shift. Door handles, hand holds/rails, dashboards,

steering wheels, controls etc should be paid particular attention to

▪ Where an item of plant may have been used by someone displaying the symptoms of

COVID-19, or a confirmed case, then the plant should either be decontaminated

thoroughly (see advice at https://www.gov.uk/government/publications/covid-19-

decontamination-in-non-healthcare-settings/covid-19-decontamination-in-non-

healthcare-settings) or parked up for a minimum of 72 hours

▪ If reasonably practicable, plant operators should be dedicated to one item of plant, or

at least the number of operators using an individual item of mobile plant should be

limited. The cab should be cleaned before it is given to a different user

Transfer stations, MBT, EfW, AD, landfills and similar In addition to the above general measures:

▪ Issue of instructions to site employees aimed at reducing the risk of transmission from

those third parties using sites. Minimise face-to-face contact – stay in mobile plant

where reasonably practicable, keep mobile plant windows closed, and if you must

speak directly maintain at least 2m separation etc

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MRFs and recycling plants In addition to the above general measures:

▪ Issue of instructions to site employees aimed at reducing the risk of transmission from

those third parties using sites. Minimise face-to-face contact – keep mobile plant

windows closed, and if you must speak directly maintain at least 2m separation etc

▪ Picking cabins may be an issue because of their enclosed nature and proximity of

pickers to each other – consider rearrangement of the work to allow every other waste

chute to be used, staggered on each side of the picking belt, to maintain adequate

Social Distancing of 2 metres

▪ Access and egress from cabins may also need to be considered, such as operatives

entering and leaving one-by-one to avoid the need for people to pass near each other

(save for in emergency situations such as a fire where the normal rules will still apply)

▪ Glove use should be reinforced for those working in picking cabins (see section above

on gloves for detail of glove use)

Some organisations have fitted, or are considering fitting, Perspex or similar screens in

picking cabins/lines (see section above under change management). Specific to picking

cabins/lines, and in addition to the general design risk assessment requirements noted in the

section above on change management, the following should also be considered:

▪ Access to critical machinery safety provisions must not be impeded or restricted by

the installation of screens. For example, access to ‘pull-wire’ emergency stop cords

▪ Any modification to or change of location of critical machinery safety provisions must

be carefully risk assessed before being carried-out to ensure that access to such

provisions and their effectiveness is not compromised. For example, the relocation of

a pull-wire emergency stop cord to a less easily accessible position to facilitate the

installation of screens, or a change in the ‘run’ of such cords which may compromise

their effective operation

▪ Emergency escape from the cabin/line

▪ Potential interference with any fixed fire systems such as sprinklers (where fitted)

▪ Ability and access to clean the screen/s (screens should be subject to the same

cleaning regimes as other equipment)

Recycling plant workers undertaking sampling and testing duties, such as for quality control

and regulatory reasons, should already be working under appropriate controls, including

adequate PPE. These controls should be maintained, and risk assessments relating to such

duties reviewed in the light of COVID-19 to ensure they remain appropriate.

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For a variety of reasons, the use of PPE (in particular, face masks and gloves) by the public

is increasing. The vast majority of PPE is not recyclable and may compromise the quality of

recycling waste streams. Used PPE should be disposed of into residual waste bins/bags by

the public, but this may not always be the case. If recycling plant operators start observing

significant amounts of used PPE appearing on picking lines and similar, they should discuss

the issue with their client. Public communications and education campaigns and publicity may

be required to encourage used PPE to be disposed of into residual waste streams.

CA/HWRC sites As CA/HWRC sites are places where members of the public may meet in numbers, the

closing of sites should be considered until Social Distancing is relaxed (but, please see above

example under change management regards bulky wastes and also in the same section on

reopening of HWRC/CA sites). If there is necessity and it is essential for CA/HWRC sites

remain open, then in addition to the above general measures:

▪ Issue instructions to site employees aimed at reducing the risk of transmission from

those third parties using sites. Minimise face-to-face contact – keep mobile plant

windows closed, and if you must speak directly maintain at least 2m separation etc.

The use of floor markings (tape or similar) or cones around containers may assist

▪ Issue instructions to cease assisting members of the public with wastes, keep Social

Distance from members of the public to reduce the risk of transmission (note – most

CA/HWRC sites are contracted to local authorities and contact should be made with

the authority as regards such measures)

▪ Items such as handrails on access steps to containers and other frequently touched

surfaces and items should be cleaned frequently

Please also see section 4 on changes and in particular the text on the reopening of

HWRC/CA sites and at https://www.gov.uk/government/publications/coronavirus-covid-19-

advice-to-local-authorities-on-prioritising-waste-collections/managing-household-waste-and-

recycling-centres-hwrcs-in-england-during-the-coronavirus-covid-19-pandemic.

Welfare facilities

To reduce the opportunity for person to person transmission and maintain Social Distancing

consideration should be given to staggering rest breaks. For example, people number could

be limited. Where capacity is reached the facility should operate a “one in, one out” situation.

Staff and supervisors should be given responsibility to police and control this. A regime

should be put in place to ensure that rest areas are thoroughly cleaned after rest breaks and

other uses (for example morning brief and afternoon debrief sessions).

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All surfaces, crockery, cutlery etc. should be thoroughly cleaned/washed after use and

surfaces should be cleaned periodically throughout the day. Items such as doorknobs should

not be forgotten. Hand washing to be promoted and actively encouraged, and provision of

wipes, sanitisers, soap to be made. HOT running water is essential.

Smoking areas are often also social gathering points. Staggering rest periods will assist but

maintaining 2m separation during smoke breaks is still required.

It is common for waste management sites to provide toilet and other welfare facilities to

visiting drivers and collection crews. HSE has reiterated that all drivers must have access to

welfare facilities in the premises they visit as part of their work. Preventing access is against

the law; equally it is not the sensible thing to do. Those who already provide reasonable

access to toilets and handwashing facilities should continue to do so. With the latest advice

for hands to be washed regularly, failure to allow access to welfare facilities may increase the

risk of the COVID-19 infection spreading. Please note that the general precautions, hygiene

and Social Distancing apply equally to all on site including third parties.

Weighbridges In addition to the general precautions listed above:

▪ Where reasonably practicable weighbridge windows to be kept closed (you may as a

possible option want to consider installing transparent shields, as is being introduced

at some supermarket check-outs) although these should not be relied on as the sole

control being used

▪ If paperwork needs to be exchanged, impermeable gloves to be used, along with

frequent washing of hands by weighbridge staff

▪ Where temporary regulatory relaxations have been put in place and as a result no

paperwork exchange or other contact with shared items such as single digital

signature pads is required, glove use may be relaxed, although frequent hand

washing will still need to be maintained as good hygiene practice

▪ If still in use, the frequent cleaning and disinfecting of items such as digital signature

pads, pens, clipboards and similar

Note – various temporary regulatory statements relating to waste transfer processes and

‘duty of care’ have been released by the main GB environmental regulators. You are advised

to keep up to date with any developments in this area, and that you ensure that you

understand the requirements relevant to your operations. If in doubt, contact your

environmental regulator for advice.

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6. Other information and links

General links

▪ https://111.nhs.uk/covid-19

▪ https://www.nhsinform.scot/self-help-guides/self-help-guide-coronavirus-covid-19

▪ https://www.nhsdirect.wales.nhs.uk/contactus/

▪ https://www.gov.uk/government/publications/covid-19-stay-at-home-guidance/stay-at-

home-guidance-for-households-with-possible-coronavirus-covid-19-infection

▪ https://www.gov.uk/government/publications/guidance-to-employers-and-businesses-

about-covid-19/guidance-for-employers-and-businesses-on-coronavirus-covid-19

▪ https://www.gov.uk/government/publications/covid-19-decontamination-in-non-healthcare-

settings

▪ https://www.ecdc.europa.eu/en/factsheet-health-professionals-coronaviruses

Links to devolved administration web sites

▪ https://www.hps.scot.nhs.uk/a-to-z-of-topics/covid-19/

▪ https://phw.nhs.wales/topics/latest-information-on-novel-coronavirus-covid-19/

▪ Specifically on Social Distancing: https://gov.wales/taking-all-reasonable-measures-maintain-physical-distancing-workplace

RIDDOR and COVID-19: Statement from the HSE

To assist in the interpretation of reporting requirements under RIDDOR (Reporting of Injuries,

Diseases and Dangerous Occurrences Regulations) regards COVID-19, the HSE (Health and

Safety Executive) has stated: “For an incident to be reportable as a disease due to

occupational exposure to a biological agent, there must be reasonable evidence suggesting

that a work-related exposure was the likely cause of the worker contracting COVID 19. Such

instances could include, for example, frontline health and social care workers (e.g.

ambulance personnel, GPs, social care providers, hospital staff etc) who have been involved

in providing care/treatment to known cases of COVID 19, who subsequently develop the

disease and there is reasonable evidence suggesting that a work- related exposure was the

likely cause of the disease. A doctor may indicate the significance of any work- related factors

when communicating their diagnosis.”

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Disclaimer and WISH This information document has been prepared by health and safety practitioners to assist

health and safety improvements in the waste management industry. It is endorsed by the

WISH (Waste Industry Safety and Health) Forum. This information document is not formal

guidance and represents good practice, which typically may go beyond the strict

requirements of health and safety law.

Nothing in this information document constitutes legal or other professional advice and no

warranty is given nor liability accepted (to the fullest extent permitted under law) for any loss

or damage suffered or incurred because of reliance on this document. WISH accepts no

liability (to the fullest extent permitted under law) for any act or omission of any persons using

this document.

This information document is not a substitute for duty holder and/or professional safety

advisor’s judgment, Notwithstanding the good practice in this document, duty holders are

responsible for ascertaining the sufficiency and adequacy of their internal and independent

procedures for verifying and evaluating their organisation’s compliance with safety law.

The Waste Industry Safety and Health (WISH) Forum exists to communicate and consult with

key stakeholders, including local and national government bodies, equipment manufacturers,

trade associations, professional associations and trade unions. The aim of WISH is to

identify, devise and promote activities to improve industry health and safety performance.